Article 1 – Preamble

This privacy policy applies to the WELLBERT company websites. The purpose of this privacy policy is to expose users of the site to:

• How their personal data is collected and processed. All data that can identify a user must be considered as personal data. These include the first and last name, age, postal address, email address, user location or IP address;
• What are the rights of users regarding this data;
• Who is responsible for the processing of personal data collected and processed;
• To whom this data is transmitted;
• Possibly, the site's policy regarding "cookie" files. This privacy policy supplements the legal notices and the General Conditions of Use that users can consult at the following address: https://www.wftb.fr/en/about/legal-notice

https://www.wftb.fr/general-conditions-of-use

Article 2 – General principles for the collection and processing of data

In accordance with the provisions of Article 5 of European Regulation 2016/679, the collection and processing of site user data complies with the following principles:

• Lawfulness, loyalty and transparency: data can only be collected and processed with the consent of the user who owns the data. Each time personal data is collected, the user will be informed that his data is collected, and for what reasons his data is collected;
• Limited purposes: the collection and processing of data is carried out to meet one or more purposes determined in these general conditions of use;
• Minimization of the collection and processing of data: only the data necessary for the proper execution of the objectives pursued by the site are collected; • Retention of reduced data over time: the data is kept for a limited period, of which the user is informed.
• Integrity and confidentiality of the data collected and processed: the data controller undertakes to guarantee the integrity and confidentiality of the data collected.

In order to be lawful, and in accordance with the requirements of Article 6 of European Regulation 2016/679, the collection and processing of personal data can only take place if they meet at least one of the conditions listed below:

• The user has expressly consented to the processing;
• The processing is necessary for the proper performance of a contract;
• The processing meets a legal obligation;
• The processing is explained by a necessity linked to the safeguarding of the vital interests of the data subject or of another natural person;
• The processing may be explained by a necessity linked to the performance of a task in the public interest or which relates to the exercise of official authority;
• The processing and collection of personal data is necessary for the purposes of the legitimate and private interests pursued by the controller or by a third party.

Article 3 – Personal data collected and processed when browsing the site

1. COLLECTED AND PROCESSED DATA AND METHOD OF COLLECTION

The personal data collected on the WFTB site are as follows:

• Pseudonym
• Email Addresses
• Name
• First name
• Gender
• Birth date
• Type of client (pro or individual)
• Country
• IP addresses
• GEDCOM Files

This data is collected when the user performs one of the following operations on the site:

• When creating the user account after online payment
• When uploading a GEDCOM file to the app
• When a user visits our website, and the Google Analytics script is triggered, to track site performance.

The data controller will keep all the data collected in its computer systems on the site and under reasonable security conditions for a period of: 3 years.

The collection and processing of data serves the following purposes: The data collected following the completion of the contact form makes it possible to respond better and faster to the needs and requests expressed. The data is therefore stored in our CRM so that the contact can be made.

1. TRANSMISSION OF DATA TO THIRD PARTIES

The personal data collected by the site is not transmitted to any third party, and is only processed by the site editor.

1. DATA HOSTING

The WFTB site is hosted by:

GANDI SAS, Simplified Joint Stock Company, whose registered office is located at 15, place de la Nation – 75011 PARIS

1. DATA SECURITY

The security of data passing through the site https://wftb.fr during navigation is ensured by the encryption of the data of the SSL certificate present on the site. This provides data encryption on corporate networks and the internet.

Article 4 – Data controller

1. THE DATA PROCESSOR

– The person responsible for processing personal data is: Philbert MAHÉ

He can be contacted as follows:

The data controller can be contacted via this email address: contact@wftb.fr or by post to Société WELLBERT, 26 rue de la mairie – 44270 LA MARNE - FRANCE.

The data controller is responsible for determining the purposes and means used to process personal data. For the exercise of your rights or any question relating to the protection of personal data, please contact : contact@wftb.fr

1. OBLIGATIONS OF THE DATA PROCESSOR

The controller undertakes to protect the personal data collected, not to transmit them to third parties without the user having been informed and to respect the purposes for which these data were collected.

In addition, the data controller undertakes to notify the user in the event of rectification or deletion of the data, unless this entails disproportionate formalities, costs and procedures for him.

In the event that the integrity, confidentiality or security of the user's personal data is compromised, the controller undertakes to inform the user by any means.

Article 5 – User rights

In accordance with the regulations concerning the processing of personal data, the user has the rights listed below.

In order for the data controller to comply with his request, the user is required to communicate to him: his first and last name as well as his e-mail address. The data controller is required to respond to the user within a maximum of 30 (thirty) days.

1. PRESENTATION OF USER RIGHTS REGARDING DATA COLLECTION AND PROCESSING
2. Right of access, rectification and right to erasure

The user may read, update, modify or request the deletion of data concerning him, by respecting the procedure set out below: The user must send an e-mail to the data processing manager. personal data, specifying the subject of his request and using the contact e-mail address provided above

1. Right to data portability

The user has the right to request the portability of his personal data, held by the site, to another site, by complying with the following procedure:

The user must send an e-mail to the personal data controller, specifying the subject of his request and using the contact e-mail address provided above.

1. Right to restriction and opposition of data processing

The user has the right to request the limitation or to oppose the processing of his data by the site, without the site being able to refuse, except to demonstrate the existence of legitimate and compelling reasons, that may prevail over the interests and rights and freedoms of the user. In order to request the limitation of the processing of his data or to formulate an opposition to the processing of his data, the user must follow the following procedure: The user must send an e-mail to the person responsible for the processing of personal data, specifying the subject of his request and using the contact e-mail address provided above.

1. Right not to be the subject of a decision based exclusively on an automated process

In accordance with the provisions of Regulation 2016/679, the user has the right not to be the subject of a decision based exclusively on an automated process if the decision produces legal effects concerning him, or the 'significantly affects in a similar way.

1. Right to determine fate of data after death

The user is reminded that he can organize what should become of his data collected and processed if he dies, in accordance with law n°2016-1321 of October 7, 2016.

1. Right to appeal to the competent supervisory authority

In the event that the data controller decides not to respond to the user's request, and the user wishes to contest this decision, or, if he thinks that he is brought infringement of one of the rights listed above, he is entitled to seize the CNIL (National Commission for Computing and Freedoms, https://www.cnil.fr) or any competent judge.

1. PERSONAL DATA OF MINORS

In accordance with the provisions of Article 8 of European Regulation 2016/679 and the Data Protection Act, only minors aged 15 or over may consent to the processing of their personal data.

If the user is a minor under the age of 15, the consent of a legal representative will be required so that personal data can be collected and processed.

The site editor reserves the right to verify by any means that the user is over 15 years old, or that he has obtained the agreement of a legal representative before browsing the website.

Article 6 – Use of “COOKIES” files

The site may use “cookie” techniques.

A "cookie" is a small file (less than 4 KB), stored by the site on the user's hard drive, containing information relating to the user's browsing habits.

These files allow it to process statistics and traffic information, to facilitate navigation and to improve the service for the convenience of the user. For the use of “cookie” files involving the saving and analysis of personal data, the consent of the user is necessarily requested. This user consent is considered valid for a maximum of 13 (thirteen) months. At the end of this period, the site will again request the user's authorization to save "cookie" files on their hard drive.

1. Opposition of the user to the use of "cookies" files by the site

Users are informed that they can oppose the recording of these “cookie” files by configuring their browser software.

For information, the user can find the steps to follow in order to configure his navigation software to oppose the recording of "cookie" files at the following addresses:

• Chromium: https://support.google.com/accounts/answer/61416?hl=fr
• Firefox: https://support.mozilla.org/en-us/kb/enable-and-disable-cookies-website-preferences
• Safari: http://www.apple.com/legal/privacy/fr/
• Internet Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or allow-cookies
• Opera: http://www.opera.com/help/tutorials/security/cookies/

If the user decides to deactivate the "cookie" files, he can continue browsing the site. However, any malfunction of the site caused by this manipulation could not be considered as being due to the publisher of the site.

1. Description of the main “cookie” files used by the site

The site editor draws the user's attention to the fact that the following cookies are used during browsing:

Cookie name: Google Analytics

– Transmitter: WELLBERT

– Purpose: Audience analysis

Article 7 – Conditions for modifying the privacy policy

This privacy policy may be consulted at any time at the address indicated below:

https://wftb.fr/en/privacy-policy

The publisher of the site reserves the right to modify it in order to guarantee its compliance with the law in force.

Consequently, the user is invited to regularly consult this privacy policy in order to stay informed of the latest changes that will be made to it. It is brought to the user's attention that the last update of this privacy policy took place on: 20/04/2021 .

Article 8 – User acceptance of the privacy policy

By browsing the site, the user certifies that he has read and understood this privacy policy and accepts its conditions, with particular regard to the collection and processing of his personal data, as well as than the use of “cookie” files.